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V0403-26 26 February 2026 · SG de Impuestos sobre el Consumo Criterion in force
IVA · empresario o profesional

Societies holding assets for sole owner's use are not entrepreneurs and exempt from VAT

The DGT confirms that societies renting property exclusively to their single shareholder are not deemed entrepreneurs or professionals and thus are not subject to VAT if they do not engage in market intervention or business activity.

The question raised

1. Treatment under Value Added Tax of the services provided by companies A, B and C to the Sole Shareholder.

The DGT's ruling

Companies incorporated solely to hold the personal assets of their shareholders for their exclusive enjoyment do not carry out business or professional activities as they do not intervene in the market. Since they do not hold the status of entrepreneur or professional, their operations are not subject to VAT and they must not charge it. Likewise, they cannot deduct the tax amount incurred in their acquisitions.

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